I import products directly from China under my own brand – am I obligated as a first placer on the market under the PPWR?

Yes. Anyone who imports goods from third countries into the EU and places them on the EU market for the first time is considered a first placer on the market within the meaning of the PPWR. You therefore bear full responsibility for the conformity of all packaging – both product packaging and shipping packaging. Delegation of this responsibility to the foreign manufacturer is not legally possible. For a binding assessment of your specific supply chain, we recommend consulting your Chamber of Commerce.

Do my shipping cartons and filling materials have to be replaced from 12 August 2026?

Not necessarily immediately, but you must be able to demonstrate that your shipping cartons and filling materials meet the new recycling requirements. Cartons must contain at least 70 % recycled content and filling materials must be recycling-compatible. Existing stock from contracts concluded before the deadline may in some circumstances be used up – however, examine the PPWR's transitional period rules carefully and document your materials in full.

I sell as a marketplace seller on Amazon – does the PPWR apply to me as well?

Yes, if you sell your own warehouse stock under your name or an own brand. The platform itself does not assume any first-placer obligations for your products. Only if Amazon provides fulfilment services (Fulfilment by Amazon) and uses its own shipping packaging in doing so does the responsibility for that packaging lie with Amazon. You remain responsible for product packaging and any transport packaging you provide.

How does the PPWR relate to my existing LUCID registration under the Packaging Act?

The PPWR supplements the existing Packaging Act (VerpackG) and will gradually supersede it. Your existing LUCID registration remains valid for the time being, but must be updated to include new packaging categories and the enhanced requirements of the PPWR. The ZSVR will make the necessary adjustments to the LUCID portal in good time. We recommend aligning the requirements with your Chamber of Commerce or a specialist adviser at an early stage to avoid gaps in your registration.

Branchenguide · PPWR

PPWR for Retail & E-Commerce: Obligations for Own-Brand Products, Direct Imports and Shipping Packaging from 12 August 2026

Retailers and online shops that sell own-brand products or import goods directly from non-EU countries will bear full responsibility as first placers on the market under EU Packaging Regulation (EU) 2025/40 – the PPWR – from 12 August 2026 onwards. This applies not only to product packaging, but expressly also to shipping cartons, filling materials, adhesive tapes and returns packaging. Acting now avoids costly remediation and safeguards market access throughout the entire EU single market.

Who in retail is affected as a first placer on the market?

The PPWR directly addresses those who place packaging on the EU market for the first time. For retailers this means: as soon as you sell under an own brand or import goods directly from third countries (China, USA, Turkey, etc.), you are considered a first placer on the market – regardless of whether you operate a physical store or an online shop.

Marketplace sellers on Amazon, Otto or similar platforms are equally affected when they offer their own warehouse stock. Only pure drop-shipping, where the manufacturer outside the EU ships directly to the end customer, may shift the responsibility – this depends on the precise contractual arrangement. Have this clarified legally, for example through your responsible Chamber of Commerce (IHK).

Shipping packaging: the underestimated cost driver

A frequently overlooked aspect of the PPWR is the regulation of transport packaging. From 12 August 2026, binding requirements apply:

Cardboard boxes must contain at least 70 % recycled content and must not be oversized. The ratio of empty space to product is regulated.
Filling materials (air cushions, foam, paper padding) are subject to material specifications; purely plastic padding without any recycled content will be restricted.
Adhesive tapes and labels must be recycling-compatible and must not impair the recyclability of the main packaging.
Returns packaging counts as an independent packaging unit if it is intended for the customer to use for returning goods – plan this into your packaging design.

Labelling and proof of recyclability

Every packaging item requires a machine-readable marking (QR code or similar) that informs the consumer about correct disposal. In addition, you must be able to provide proof of recyclability for each type of packaging – either through your own assessment in accordance with harmonised EU standards or through a recognised certification procedure.

For own-brand retailers this means in concrete terms: obtain written confirmation from your packaging supplier regarding material properties and recyclability. This documentation must be presented upon request by the authorities.

Registration obligation and licensing

First placers on the market must register in a producer/placer register in each EU member state in which they first place packaging on the market. In Germany this is handled by the Central Packaging Register Office (ZSVR) via the LUCID register. Those already registered under the Packaging Act (VerpackG) must supplement their registration with the new PPWR categories.

Practical immediate measures for retailers

1. Stocktaking: Inventory all packaging types – product packaging, shipping carton, filling material, adhesive tape, returns solution. 2. Supplier audit: Request an up-to-date material data sheet and a declaration of recyclability from every packaging supplier. 3. Review direct imports: Clarify for imports from non-EU countries who is formally considered the first placer on the market – you or an EU-based authorised representative. 4. Update LUCID: Review your existing LUCID registration and add any missing packaging categories. 5. Legal advice: For binding information on your individual situation, contact your responsible Chamber of Commerce or a lawyer specialising in packaging law.

Häufige Fragen

I import products directly from China under my own brand – am I obligated as a first placer on the market under the PPWR?: Yes. Anyone who imports goods from third countries into the EU and places them on the EU market for the first time is considered a first placer on the market within the meaning of the PPWR. You therefore bear full responsibility for the conformity of all packaging – both product packaging and shipping packaging. Delegation of this responsibility to the foreign manufacturer is not legally possible. For a binding assessment of your specific supply chain, we recommend consulting your Chamber of Commerce.
Do my shipping cartons and filling materials have to be replaced from 12 August 2026?: Not necessarily immediately, but you must be able to demonstrate that your shipping cartons and filling materials meet the new recycling requirements. Cartons must contain at least 70 % recycled content and filling materials must be recycling-compatible. Existing stock from contracts concluded before the deadline may in some circumstances be used up – however, examine the PPWR's transitional period rules carefully and document your materials in full.
I sell as a marketplace seller on Amazon – does the PPWR apply to me as well?: Yes, if you sell your own warehouse stock under your name or an own brand. The platform itself does not assume any first-placer obligations for your products. Only if Amazon provides fulfilment services (Fulfilment by Amazon) and uses its own shipping packaging in doing so does the responsibility for that packaging lie with Amazon. You remain responsible for product packaging and any transport packaging you provide.
How does the PPWR relate to my existing LUCID registration under the Packaging Act?: The PPWR supplements the existing Packaging Act (VerpackG) and will gradually supersede it. Your existing LUCID registration remains valid for the time being, but must be updated to include new packaging categories and the enhanced requirements of the PPWR. The ZSVR will make the necessary adjustments to the LUCID portal in good time. We recommend aligning the requirements with your Chamber of Commerce or a specialist adviser at an early stage to avoid gaps in your registration.

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